v2888-1244

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stipulated herein shall not be paid until all of the

construction and erection work of all the dwell-

ing units has been finished and finally accepted

by the contracting officer."

It is conclusive, therefore, that this income should

have been allocated to the year 1943.

CONCLUSION

We respectfully submit that that portion of the

decision of the Tax Court of the United States hold-

ing as income for 1942 the item involved in Periodical

Estimate No. 6, Petitioners' Exhibit 7 (R. 32, 33, 34)

certified on January 6, 1943 by Appellant Dally, for

the sum of $122,875.50 (90% of $136,528.34) be re-

versed and that this Court find and determine that

the said item was properly includible in reportable

income by the Appellants for the tax year 1943.

Respectfully submitted,

HILE, HOOF & SHUCKLIN

GERALD D. HILE

CLIFFORD HOOF

GERALD SHUCKLIN

Attorneys for Appellants

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